Reed v. State, 291 Ga. 10

Reed was indicted for malice murder of Gatson, felony murder during aggravated assault, aggravated assault, and aggravated battery of Gatson’s sister Porter.
A jury acquitted Reed of malice murder but convicted him on the felony murder and the two assault/battery counts.
The trial court, as a recidivist, sentenced Reed to life without parole for felony murder, plus 20 years for aggravated assault and 20 years consecutive for aggravated battery.
The aggravated assault sentence was later vacated by the State’s concession, which Reed appeals.
Porter identified Reed as the assailant; Reed fled the scene, made inconsistent statements, and later admitted to police and his brother that he had harmed someone.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the felony murder indictment legally sufficient?	Reed argues the predicate aggravated assault was not properly alleged.	State contends the indictment implicitly alleged a deadly weapon through the hatchet.	Indictment sufficiently alleged aggravated assault and deadly-weapon use.
Were similar-transaction evidences properly admitted?	Reed contends the prior 2000 incident is dissimilar and inadmissible.	State argues three-prong Williams test satisfied; similarities support intent and MO.	Trial court did not abuse discretion; evidence admissible under Williams test.
Was trial counsel ineffective for failing to object to closing arguments and similar-transaction evidence?	Counsel’s failure to object prejudiced Reed.	No reasonable probability the outcome would differ; overwhelming evidence of guilt.	No ineffective-assistance violation; trial counsel not prejudicially deficient.
What standard governs appellate review of the trial court’s evidentiary rulings on similar transactions?	Standard should be the same for findings and discretion.	Two standards may apply; abuse of discretion for admissibility, clearly erroneous for facts.	Adopted dual-standard approach: fact findings reviewed for clearly erroneous; admissibility for abuse of discretion.

Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard for criminal conviction)
Swanson v. State, 282 Ga. 39, 644 S.E.2d 845 (2007) (sufficiency of evidence and standard of review in Georgia)
Rich v. State, 274 Ga. 695, 558 S.E.2d 720 (2002) (evidence sufficiency and standard of review)
Edmond v. State, 283 Ga. 507, 661 S.E.2d 520 (2008) (demurrer and indictment specificity)
Morgan v. State, 275 Ga. 222, 564 S.E.2d 192 (2002) (death-by-weapon implicit-pleading rule)
Borders v. State, 270 Ga. 804, 514 S.E.2d 14 (1999) (death-weapon and deadly-weapon pleading)
Moore v. State, 273 Ga. 11, 537 S.E.2d 334 (2000) (similarity requirement for admissible similar transactions)
Harvey v. State, 284 Ga. 8, 660 S.E.2d 528 (2008) (three-prong Williams test for similar transactions)
Jones v. State, 288 Ga. 431, 704 S.E.2d 776 (2011) (ineffective assistance standard under Strickland; prejudice inquiry)
Lloyd v. State, 280 Ga. 187, 625 S.E.2d 771 (2006) (mistrial and closing arguments; curative instructions)
Hill v. State, 290 Ga. 493, 722 S.E.2d 708 (2012) (procedural posture on vacated sentence)